Export of mercury and mercury waste Sven Hagemann

Export of mercury and mercury waste Sven Hagemann GRS

Export of elemental mercury and mercury waste When? • As long as national/ regional storage/ treatment/ disposal facilities do not exist • If quantities are too small to justify a national storage/ treatment/ disposal facility Examples: • Export of by-product mercury from Chile/ Peru to USA for refining and re-export (will end from 1 January 2013) • Export of mercury contaminated waste (catalysts, sludges) from the oil/ gas industry in Indonesia to Germany and Switzerland for recycling 2

Export concepts A) Transport B 1) Warehouse storage, 40 years (USA) B 2) Stabilization and underground disposal (Europe) So far, available only for mercury generated in the USA Mercury remains in the ownership and responsibility of the producer 3

Legal prerequisites and requirements for the export of commodity mercury • No export ban for commodity mercury (currently only in the EU, soon in US) export may be further restricted in the mercury convention (e. g. export only for accepted uses, environmentally sound storage and disposal) • No import ban for commodity mercury (some European countries) • Application of international rules for shipment of dangerous goods, e. g. ADR (UNECE) (road), IMDG (sea), GHS, UN Recommendations on the Transport of Dangerous Goods • Classification, • Labelling • Packaging • Safety measures 4

Legal prerequisites and requirements for the export of mercury waste • No export ban for mercury waste (Basel Convention: no export of hazardous waste to non-parties no export to area south of 60° South latitude no export from EU, OECD countries to other countries (Ban amendment, not entered into force) export may be further restricted in the mercury convention (e. g. export only for the purpose of environmentally sound disposal) • No import ban for hazardous waste (> 100 developing countries) • Shipment according to international rules for shipment of dangerous goods Classification, Labelling, Packaging, Safety measures (ADR, UN, IMDG, GHS) • Prior informed consent, notification, proof of contract, documentation (Basel Convention) 5

Export of elemental mercury as commodity or waste? Elemental mercury Intented for disposal (treatment, storage before disposal, recycling, final disposal) waste (Basel Convention) Mercury from a certain source waste to be disposed (national definition, e. g. EU) Mercury not considered waste intented for warehouse storage (storage of commodities) commodity 6

Containers for shipment of elemental mercury Sea transport: only 3 l flask (e. g. on palettes) Transport on land: according to national/ regional requirements: 3 l flasks, 1 t containers, other containers 7

Cost of export to another region A) Transport Example: Export of by-product mercury from Peru to USA: 850 to 1, 140 USD/t B 1) Warehouse storage, 40 years 7, 200 to 16, 100 USD/t (planned DOE facility, USA) Transport + Storage: ~8, 000 + 17, 000 USD/t B 2) Stabilization and underground disposal 2, 000 EUR ~ 2, 800 USD/t Transport + Disposal: ~ 4, 000 USD/t may be more expensive that regional solution 8

Opportunities and challenges of export to another region Opportunities Challenges • Use of established processes and facilities elsewhere • Probably few legal obstacles for export to developed countries • Foreign facilities may not be available for non-domestic mercury • Public acceptance in importing state • Storage: difficult issues of ownership and liability • Export of waste to facility in developing country hampered or even excluded by national and international law 9